PD-1341-14
FILED IN COURT OF CRIMINAL APPEALS
COURT OF CRIMINALAPPEALS AUSTIN, TEXAS
Transmitted 7/30/2015 10:58:36 AM
August 3, 2015 Accepted 8/3/2015 8:32:45 AM
ABEL ACOSTA
ABELACOSTA, CLERK No. PD-1341-14 CLERK
TO THE
COURT OF CRIMINAL APPEALS
OF THE STATE OF TEXAS
STACY STINE CARY § APPELLANT
v. §
THE STATE OF TEXAS APPELLEE
On Appeal from the Court of Appeals
for the Fifth Judicial District of Texas at Dallas
Court of Appeals No. 05-12-01421-CR
MOTION OF THE PILLAR OF LAW INSTITUTE
FOR ADMISSION OF STEPHEN R. KLEIN PRO HAC VICE
JAMES "TREY" TRAINOR III STEPHEN R. KLEIN
State Bar No. 24042052 Pillar of Law Institute
Beirne, Maynard & Parsons, L.L.P. 455 Massachusetts Ave. NW
rth
401 W 15l St Ste. 359
Ste. 845 Washington, DC 20001-2742
Austin, TX 78701-1667 (202) 815-0855 (Tel.)
(512) 623-6700 (Tel.) stephen.klein@pillaroflaw.org
ttrainor(a>brnpllp.com
OF COUNSEL FOR AMICUS
COUNSEL OF RECORD
NOW COMES, Stephen R. Klein, a non-resident attorney, and respectfully
requests permission to appear in this Honorable Court Pro Hac Vice on behalf of the
Pillar of Law Institute. As reason therefore, and upon my oath, I state:
1. My address and telephone numbers are: Stephen R. Klein, Pillar of Law
Institute, 455 Massachusetts Ave., ste. 359, Washington, DC 20001-2742;
202.815.0955.
2. I will be associated in the case with James "Trey" Trainor III, a practicing
lawyer and a member in good standing of the State Bar of Texas. His address
and telephone number are: Beirne, Maynard and Parsons, L.L.P., 401 W 15
Street, ste. 845, Austin, TX 78701-1667; 512.623.6700. His Texas Bar card
number is: 24042052.
3. In the past two years, I have appeared pro hac vice in Texas as counsel for
amicus curiae in the following cases: DeLay v. State, 443 S.W.3d 909, No. PD-
1465-13 (Tex. Crim. App.) (Oct. 1, 2014); Cary v. State, 460 S.W.3d 731, No.
05-13-01010-CR (Tex. App.-Dallas) (Mar. 25, 2015).
4. I am an active member in good standing of the Illinois Supreme Court and the
Michigan Supreme Court. I am also a member in good standing of the United
States District Court for the Northern District ofIllinois, the United States Court
of Appeals for the Tenth Circuit, and the United States Supreme Court.
5. I have not been the subject of any disciplinary action by any bar or courts during
the last five years.
6. I have not been denied admission to the courts of any state or to any federal
court during the last five years.
7. I am familiar with the State Bar Act, Rules of the State Bar of Texas governing
the conduct of its members, and the Texas Disciplinary Rules of Professional
Conduct, and I will comply with these rules so long as such proceeding is
pending.
8. This motion is accompanied by a motion of Trey Trainor stating that I am a
reputable attorney fit to participate in this particular proceeding.
9. I have included an acknowledgment issued by the Board of Law Examiners.
WHEREFORE, based on the foregoing, Stephen Klein respectfully prays this
court will allow me to appear in this matter Pro Hac Vice on behalf of the Pillar of
Law Institute for such other and further relief that may be awarded at law or in equity.
Signed and sworn under the pains and penalties of perjury,
Isi Stephen Klein
Stephen R. Klein
Pillar of Law Institute
455 Massachusetts Ave.
Ste. 359
Washington, DC 20001-2742
Tel: 202.815.0955
stephen.klein@pillaroflaw.org
CERTIFICATE OF SERVICE
I certify that on July 30, 2015, a true and correct copy of this Motion of the
Pillar of Law Institute for Admission of Stephen R. Klein Pro Hac Vicewas served
by electronic filing on appellate counsel of record in this proceeding as listed below.
Counsel for State Counsel for Appellant
Ken Paxton John M. Helms
Attorney General of Texas Fitzpatrick, Hagood, Smith & Uhl LLP
Chateau Plaza, Ste. 1400
Charles E. Roy 2515McKinney
First Assistant Attorney General Dallas, Texas 75201
Adrienne McFarland
Deputy Attorney General
for Criminal Justice
Edward L. Marshall
Chief, Criminal Appeals Division
Joseph P. Corcoran
Assistant Attorney General
Supervising Attorney for Non-Capital
Appeals Criminal Appeals Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Isi Trey Trainor
James "Trey" Trainor III
Board of Law Examiners
Appointed by the Supreme Court of Texas
P.O. Box 13486 * Austin, Texas 78711-3486
Acknowledgment Letter
Non-Resident Attorney Fee
July 22, 2015
To: Stephen Klein
Via: stephen.klein@pillaroflaw.org
According to Texas Government Code §82.0361, "a nonresident attorney
requesting permission to participate in proceedings in a court in this state shall
pay a fee of $250 for each case in which the attorney is requesting to
participate."
This Acknowledgement Letter serves as proof that the Board of Law
Examiners has received $250 in connection with the following matter:
Non-resident attorney: Stephen Ralph Klein
Case: PD-1341-14
Texas court or body: Texas Court of Criminal Appeals Austin
After satisfying the fee requirement, a non-resident attorney shall file a
motion in the Texas court or body in which the non-resident attorney is
requesting permission to appear. The motion shall contain the information and
statements required by Rule XIX(a) of the Rules Governing Admission to the Bar
of Texas. The motion must be accompanied by this Acknowledgment Letter and
by a motion from a resident practicing Texas attorney that contains the
statements required by Rule XIX(b).
The decision to grant or deny a non-resident attorney's motion for permission
to participate in the proceedings in a particular cause is made by the Texas court
or body in which it is filed.
For more information, please see Rule XIX of the Rules Governing Admission
to the Bar of Texas and §82.0361 of the Texas Government Code, which can be
found on the Board's website.
Sincerely,
Susan Henricks
Executive Director
FILED IN
PD-1341-14
COURT OF CRIMINAL APPEALS
COURT OF CRIMINALAPPEALS
AUSTIN, TEXAS
August 3, 2015 Transmitted 7/30/2015 11:03:39 AM
Accepted 8/3/2015 8:32:21 AM
ABEL ACOSTA
ABEL ACOSTA, CLERK No. PD-1341-14
CLERK
TO THE
COURT OF CRIMINAL APPEALS
OF THE STATE OF TEXAS
STACY STINE CARY § APPELLANT
v. §
THE STATE OF TEXAS § APPELLEE
On Appeal from the Court of Appeals
for the Fifth Judicial District of Texas at Dallas
Court of Appeals No. 05-12-01421-CR
MOTION OF JAMES "TREY" TRAINOR SUPPORTING
ADMISSION OF STEPHEN R. KLEIN PRO HAC VICE
JAMES "TREY" TRAINOR III STEPHEN R. KLEIN
State Bar No. 24042052 Pillar of Law Institute
Beirne, Maynard & Parsons, L.L.P. 455 Massachusetts Ave. NW
401 W 15th St Ste. 359
Ste. 845 Washington, DC 20001-2742
Austin, TX 78701-1667 (202) 815-0855 (Tel.)
(512) 623-6700 (Tel.) stephen.klein(g),pillaroflaw.org
ttrainor(a>bmpllp.com
OF COUNSEL FOR AMICUS
CO UNSEL OF RECORD
NOW COMES, James "Trey" Trainor III, respectfully requesting this
Honorable Court grant the motion on behalfofthe Pillar ofLaw Institute for admission
of Stephen R. Klein Pro Hac Vice. Upon my oath, I state:
1. Stephen R. Klein will be associated with me in the proceedings of this cause.
2. I find Stephen R. Klein to be a reputable attorney and recommend that he be
granted permission to participate in this proceeding before this Court.
Respectfully submitted,
Isi Trey Trainor
JAMES "TREY" TRAINOR III
State Bar No. 24042052
Beirne, Maynard & Parsons, L.L.P.
401 W 15th St
Ste. 845
Austin, TX 78701-1667
(512) 623-6700 (Tel.)
ttrainor@bmpllp.com
CERTIFICATE OF SERVICE
I certify that on July 30, 2015, a true and correct copy of this Motion
Supporting Admission of Stephen R. Klein Pro Hac Vice was served by electronic
filing on appellate counsel of record in this proceeding as listed below.
Counsel for State Counsel for Appellant
Ken Paxton John M. Helms
Attorney General of Texas Fitzpatrick, Hagood, Smith & Uhl LLP
Chateau Plaza, Ste. 1400
Charles E. Roy 2515McKinney
First Assistant Attorney General Dallas, Texas 75201
Adrienne McFarland
Deputy Attorney General
for Criminal Justice
Edward L. Marshall
Chief, Criminal Appeals Division
Joseph P. Corcoran
Assistant Attorney General
Supervising Attorney for Non-Capital
Appeals Criminal Appeals Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Isi Trey Trainor
James "Trey" Trainor III